BG5150 Posted July 16, 2019 Posted July 16, 2019 I know I can add a discretionary match to a safe harbor plan mid year. But can I add a stated match? We have a client that wants to make a big match on top of the 3% SH. More than the discretionary match constraints would allow. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
BG5150 Posted July 17, 2019 Author Posted July 17, 2019 To answer my own question, yeah. At first, it's not he list of prohibited changes, but you can if certain requirements are met. A mid-year change to modify (or add) a formula used to determine matching contributions (or the definition of compensation used to determine matching contributions) if the change increases the amount of matching contributions, or to permit discretionary matching contributions. However, a plan may make such a mid-year change if: a. the change is adopted at least 3 months before the end of the plan year, b. the change is made retroactive for the entire plan year, and c. the plan sponsor gives an updated safe harbor notice and additional election opportunities to each employee otherwise required to be provided a safe harbor notice at least 3 months prior to the end of the plan year. QKA, QPA, CPC, ERPATwo wrongs don't make a right, but three rights make a left.
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